NCASI Air Quality Program Lee Carlson NCASI Arkansas Environmental - - PowerPoint PPT Presentation

NCASI Air Quality Program

Lee Carlson NCASI Arkansas Environmental Federation Air Seminar - May 9, 2018

Air Quality Program

Targeted Studies to Address Technical and Regulatory Needs

2 Arkansas Environmental Federation Air Seminar – May 2018

Emission Measurement Methods and Instrument Evaluations

• Filterable PM2.5 and Condensable PM (CPM)
• Low-level HAPs and VOC speciation
• Instrumentation methods (FTIR, PM2.5

measurement using ambient monitors)

• Next gen portable monitors

Emission Factor Development

• Fill critical gaps in emissions data
• Develop one-of-a-kind emissions database –

used for permitting, PSD impact analyses and inventories

Focused Member Technical Support

• Impacts of operating parameters on emissions
• Emission test planning and data review
• Mill Environmental issues

Informing Regulatory Development and Implementation

• Communicate technical studies and analyses to

EPA and States and enable development of achievable regulations

• Regulatory compliance tools and compliance

demonstration support

Air Quality

Emission Measurement Methods – USEPA Method 202

Federal Reference Method for Condensable Particulate Matter (CPM)

3 Arkansas Environmental Federation Air Seminar – May 2018

• Need for reliable PM2.5 and CPM data for permitting and PSD applicability analyses
• Data gaps and bad data frequently derail viable expansion projects
• NCASI research indicates USEPA Method 202 yields positively biased measurements

Why?

• Best practices for Method 202 (CPM) to minimize blank (zero) bias
• Collaborative research with EPA on artifact bias due to ammonia (NH3) and SO2
• Alternate methods to minimize artifact bias

How?

Measurement Method Research and T echnical Fixes

• Reliable data for natural gas boilers, paper machines and combustion sources
• Data widely used for PSD analyses and permitting
• NCASI technical credibility and direct interactions with EPA / state agencies

critical to achieve favorable permitting outcomes

What?

Relevant and Timely Emission Factors

EPA Method 202 for Condensable Particulate Matter (CPM)

4

 Zero Bias



Reagent impurities, sampling environments and work-practices result in measurement bias



Gravimetric mass from blank run incorporating all method-related steps, except source sampling

 Artifact Bias



Potential for SO2 oxidation and capture as sulfate



Greatly increased in the presence

• f ammonia



Ammonium and sulfate erroneously quantified as CPM

Arkansas Environmental Federation Air Seminar – May 2018

Method 202 Zero Bias Data – Summary

Arkansas Environmental Federation Air Seminar – May 2018 5

 Reduction in gravimetric mass from

~5 mg to 2 mg

 Are we splitting hairs?

 Depends on source being sampled  Bias can be a significant fraction of

CPM on low emitting sources – paper machines and natural gas boilers

EPA FTRB NCASI Lab Field 1 Field 2 Field 1 and 2 Pre-Best Practices 5.33 5.02 With Best Practices 1.65 1.85 1.78 1.82 1 2 3 4 5 6

Zero Bias, mg

Laboratory Studies

• n Method 202

Artifact Bias

➢ Synthetic gas mixtures with known

concentrations of SO2 and NH3

➢ Mixed with moisture, heated, and

sampled through Method 202 train

➢ Concentrations confirmed with

real-time FTIR measurement

➢ Used for assessment of

artifact ammonium sulfate formation

Arkansas Environmental Federation Air Seminar – May 2018 6

Impact of Ammonia on Method Artifact Bias – Method 202

7

At a given SO2 concentration (200 ppm) ammonium plus sulfate proportional to ammonia content

R² = 0.94

0.00 50.00 100.00 150.00 5 10 15 20 25

Sulfate Concentration (mg/dscm) Ammonia Concentration (ppm by vol. dry) Captured Sulfate Normalized to Sample Volume as Function of NH3 Concentration (20% Moisture, 200 ppm SO2)

3.2 mg Sulfate 55 mg Ammonium + Sulfate 136 mg Ammonium + Sulfate Arkansas Environmental Federation Air Seminar – May 2018  55 mg equates to 0.04

lb/MMBtu for a coal fired source (based on a

• ne cubic meter sample

volume)

 PM limit for existing

coal fired sources under boiler MACT = 0.04 lb/MMBtu

 PM limit for new coal

fired sources under boiler MACT = 0.0011 lb/MMBtu

Capture of SO2 and NH3 as Sulfate and Ammonium (Dilution Tunnel Method Versus Method 202)

8 Arkansas Environmental Federation Air Seminar – May 2018

 Dilution tunnel

method simulates discharge to atmosphere

 Most of the

ammonium and sulfate captured in Method 202 is method artifact

Evaluation of OTM-036 to Measure Filterable PM2.5 Emissions from Sources with Wet Control Devices

9 Arkansas Environmental Federation Air Seminar – May 2018

• Need for reliable filterable PM2.5 data for permitting and PSD
• Current EPA guidance (filterable PM = filterable PM2.5) can lead to

gross overestimates

• Important given the low 10 tpy PM2.5 PSD threshold

Why?

• Co-funding development and refinement of particulate pre-cutter used to

remove water droplets and larger (>20µm) particles

• In-field implementation and evaluations on lime kilns, smelt dissolving tanks

and thermal oxidizers with wet scrubbers ongoing

How?

Measurement Method Research and T echnical Fixes

• Data for wet PCD combustion sources and paper machine wet-end sources
• Critical for PSD analyses and permitting
• Call us for more information

What?

Relevant and Timely Emission Factors

Emission Factor Development

PM2.5 and CPM Emissions from Natural Gas Boilers

Why?

 Many natural gas boiler conversions

• r installations underway

 AP-42 factors reflect older test

methods and appear to be limited by detection limit issues

 NCASI identified opportunity to

better understand test method performance on low emitting source

 Goal – fill critical data gaps with

scientifically defensible information.

Arkansas Environmental Federation Air Seminar – May 2018 10

NCASI stack testing involved 16 to 24-hour sample runs to address Detection Limit issues

Regulatory Development & Implementation

PM2.5 Related Technical Outreach

Why?

Recent PM2.5 Related Regulatory Activity

 When NCASI findings are used to inform

regulatory and policy decisions, our utility as a reputable source of data and science is improved

 Goal – assist industry and regulators

in development of reasonable, achievable and scientifically valid emissions standards, practices and regulations

 Wisconsin PM2.5 Modeling and Permitting

Guidance

 WI DEQ issued guidance that PM2.5 emissions

from non-combustion sources are to be excluded from most permitting activities. The stated assumption is that mechanical sources are not significant

 NCASI supplied data to support justification  EPA Changes to Test Methods  EPA has proposed changes to M202 that

implement and support NCASI results from the zero bias work.

 EPA is beginning to work on alternative

strategies to address M202 artifact bias

Arkansas Environmental Federation Air Seminar – May 2018 11

Regulatory Support Activities

12

Boiler MACT

• Technical justifications for work

practice standards for D/F

• Guidance to set emission standards for

Hg based on method detection and quantitation limits

• Floor analyses during various

reconsiderations

• Parallel floor analysis to support EPA

reanalysis of floor data in response to Dec 2016 remand

Subpart MM RTR

• Reviews of facility inventories at EPA’s

request to identify data quality issues

• NCASI involvement in emissions

inventory corrections critical in lowering risks to acceptable with Ample Margin of Safety in Subpart S and MM RTRs

• Additional involvement to support

potential remand/reconsideration of final rule expected

Outreach to State Regulatory Agencies

• Communicating key technical studies to

EPA and State regulatory agencies for use in developing guidance that streamlines permitting

• Potential for PM2.5 emissions from wood

handling sources

• PM2.5 data from paper machines and

natural gas boilers

• Options to treat PM2.5 data below

method detection limits (MDL)

• NCASI work informed recent PM2.5

permitting guidance in WI

• NCASI summary enabled MI

facility to get relief from the PM2.5 modeling requirement for Title V renewal Arkansas Environmental Federation Air Seminar – May 2018

Member Support

Why?

Development of PM2.5 Emission Factors for Paper Machines

 PM2.5 from Paper Machines can be

significant driver of modeled ambient impacts

 Handling of detection limit limited data

plays a key role

 Key Takeaway: Call Us

PM2.5 Emissions, tons/yr

Method Used to Treat Vent-Level Data < MDL @ Detected Mass @ MDL Data <MDL = 0

Small Paper Machine Tissue

18.5 27.8 1.4

Linerboard

3.0 3.6 2.4

Large Paper Machine Tissue

91.4 138 5.9

Linerboard

13.8 17.2 10.8

60.5% 39.5% PM2.5 Fenceline Concentration Impact Paper Machine Remaining Mill 8.3% 91.7% Annual PM2.5 Emissions

Arkansas Environmental Federation Air Seminar – May 2018 13

Member Support – Contd.

T est Planning and Preparation Emissions T est Report Review

Arkansas Environmental Federation Air Seminar – May 2018 14

 NCASI assistance in test planning

 Recommend appropriate test methods  Supply expected and/or typical

concentrations to plan logistics and run-times

 Identify potential issues

 Example: Testing at wood-fired boiler

yielded very high CPM results

 NOx control was activated (at near-

maximum) during high CPM test

 Ammonium sulfate artifact was suspected  Follow-up IC analyses of the inorganic

residues confirmed high concentrations

• f ammonium and sulfate ions

 Key Takeaway: Call Us!

Emerging Focus Areas

15

Next Generation Monitors

• Citizen science initiatives and the use of screening

tools taking hold at EPA and States

• Track progress in EPA evaluations of Next Gen monitors –

specifically PM2.5 and VOC monitors

• Conduct product spec and literature reviews to

understand limitations of underlying technologies

• Conduct evaluations around Forest products Industry sources

to identify matrix interferences and other limitations

Engage with EPA during NAAQS Review Process

• Regulations, compliance and license to operate

increasingly driven by NAAQS

• Systematic review and critique of key epidemiology and

exposure assessment studies used by EPA to justify revisions to NAAQS standards

• Explore opportunities to engage and comment on the

Integrated Science Assessments

Arkansas Environmental Federation Air Seminar – May 2018

Lee Carlson lcarlson@ncasi.org (352) 244-0914